Richard M. Young, Jr. A/K/A Richard Young v. Texas Parks and Wildlife Department, John Silovsky as Wildlife Division Director of Texas Parks and Wildlife Department, and the State of Texas
Opinion
ACCEPTED 15-24-00052-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 7:20 PM No. 15-24-00052-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH DISTRICT COURT OF APPEALS (AUSTIN ) TEXAS AUSTIN, 2/12/2025 7:20:19 PM CHRISTOPHER A. PRINE Clerk Richard M. YOUNG, Jr. a/k/a Richard Young, Appellant vs. TEXAS PARKS & WILDLIFE DEPARTMENT, et al., Appellees.
APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION TO FILE REPLY BRIEF
Appellant Richard M. Young a/k/a Richard Young (“Young”) has a Reply Brief due to this Court on February 18, 2025. Due to unforeseen health issues (head injury),1 the undersigned needs more time to prepare a Reply Brief responsive to the Brief filed by Appellees. Thus, Young respectfully requests this Court grant him a 20-day extension to file his
The undersigned has had to spend extra time on testing (MRI w/o contrast, MRI w/contrast, CT w/o contrast, & CT w/contrast) over the past three weeks due to a head injury. The undersigned, based on this injury, has lost multiple work days to medical appointments to address this injury and to attend the multitude of testing ordered by medical professionals. Due to the significant issues presented by this case, some of which are issues of first impression for Texas law, the undersigned has been denied the time needed to properly brief a responsive filing in this extraordinary case.
Reply Brief, which would make Young’s Reply Brief due on March 10, 2025. Appellees are unopposed to this Motion.
Respectfully submitted, Kimberly S. Keller KELLER STOLARCZYK PLLC W. Bandera Road No. 114-PMB 800 Boerne, Texas 78006 Tele: 830.981.5000 /s/Kimberly S. Keller Kimberly S. Keller SBN: 24014182 Email: [email protected] APPELLANT’S COUNSEL
CERTIFICATE OF CONFERENCE & SERVICE On February 12, 2025, I conferred with Ian Lancaster, opposing counsel, who advised Appellees are opposed to this Motion; further, on this same date, this Motion was served on those listed below through this Court’s e-filing service: Counsel for Appellees: KEN PAXTON, Attorney General of Texas; BRENT WEBSTER, First Asst. Attorney General; JAMES LLOYD, Deputy Attorney General for Civil Litigation; KELLIE E. BILLINGS-RAY, Chief, Environmental Protection Division, OFFICE OF THE ATTORNEY GENERAL, Environmental Protection Division, P.O. Box 12548, MC066, Austin, Texas 78711-2548 IAN LANCASTER, Asst. Attorney General, Email: [email protected] H. CARL MYERS, Asst. Attorney General, Email: [email protected] HEATHER COFFEE, Asst. Attorney General, Email: [email protected]
Counsel for Texas Animal Health Commission: KAREN L. WATKINS, Asst. Attorney General, Administrative Law Division, Office of the Attorney General, P.O. Box 12548, Austin, Texas 78711, Email: [email protected]
/s/Kimberly S. Keller Kimberly S. Keller
Automated Certificate of eService This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Kimberly Keller on behalf of Kimberly Keller Bar No. 24014182 [email protected] Envelope ID: 97320358 Filing Code Description: Motion Filing Description: Appellant's UNOPPOSED Second Extension (Based on Health Reasons) to File Reply Brief Status as of 2/13/2025 7:17 AM CST Associated Case Party: State Of Texas Name BarNumber Email TimestampSubmitted Status Kellie E.Billings-Ray [email protected] 2/12/2025 7:20:19 PM SENT Ian Lancaster [email protected] 2/12/2025 7:20:19 PM SENT Laura Courtney [email protected] 2/12/2025 7:20:19 PM SENT H. CarlMyers [email protected] 2/12/2025 7:20:19 PM SENT James ScottMcCarley [email protected] 2/12/2025 7:20:19 PM SENT
Case Contacts Name BarNumber Email TimestampSubmitted Status Karen LWatkins [email protected] 2/12/2025 7:20:19 PM SENT Kimberly SKeller [email protected] 2/12/2025 7:20:19 PM SENT
Case-law data current through December 31, 2025. Source: CourtListener bulk data.